Knowles v. Mirzayance
- Decided
- March 24, 2009
- Docket
- 07-1315
- Status
- Published
- Jurisdiction
- Federal
Cited 2,888 timesNo negative treatment found in this library
What later courts said
- holding that in the insanity defense context, counsel is not obligated to raise claims that he "reasonably believed [were] doomed to fail" — Honie v. State (2014)
- holding that petitioner failed to establish that his counsel's performance was ineffective under both section 2254(d) and de novo review — Reese v. Secretary, Florida Department of Corrections (2012)
- concluding that attorneys are not required to raise a defense that is “almost certain to lose.” — Kayle Barrington Bates v. Secretary, Florida Department of Corrections (2014)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
Justice Thomas delivered the opinion of the Court. † A federal court may grant a habeas corpus application arising from a state-court adjudication on the merits if the state court’s decision “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.” 28 U. S. C. § 2254(d)(1). In this case, respondent Alexandre Mirzayance claimed ineffective assistance of counsel because his attorney recommended withdrawing his insanity defense. The California courts rejected this claim on state postconviction review. We must decide whether this decision was contrary to or an unreasonable application of clearly established federal law. We hold that it was not. Whether reviewed under the standard of review set forth in § 2254(d)(1) or de novo, Mirzayance failed to establish that his counsel’s performance was ineffective, see Strickland v. Washington, 466 U. S. 668 (1984).
I
Mirzayance confessed that he stabbed his 19-year-old cousin nine times with a hunting knife and then shot her four times. At trial, he entered pleas of not guilty and not guilty by reason of insanity (NGI). Under California law, when both of these pleas are entered, the court must hold a bifurcated trial, with guilt determined during the first phase and the viability of the defendant’s NGI plea during the second. Cal. Penal Code Ann. § 1026(a) (West Supp. 2008). During the guilt phase of Mirzayance’s trial, he sought to avoid a conviction for first-degree murder by obtaining a verdict on the lesser included offense of second-degree murder. To [*115] that end, he presented medical testimony that he was insane at the time of the crime and was, therefore, incapable of the premeditation or deliberation necessary for a first-degree murder conviction. The jury nevertheless convicted Mirzayance of first-degree murder.
Statutes cited
Cite this
Knowles v. Mirzayance, 556 U.S. 111 (2009)Read the full opinion
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